ALFI commented on Solvency II Delegated Regulation

6 Feb 2018 | Statements and Position Papers  

ALFI took the opportunity to provide high level comments on the second set of advice on specific items in the Solvency II Delegated Regulation, focusing in particular on the risk margin and its impact on the insurance world and thereby the impact on the asset management world.

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Furthermore, ALFI welcomed the proposed simplification of the look-through approach excluding unit-linked funds from the 20% threshold established by Article 84(3) of the Delegated Regulation. Finally, ALFI pointed to the high complexity of EIOPA’s proposal for modelling the credit rating of unrated debt through internal models and for enabling unlisted equities to receive the capital charge of listed equities.